The country of origin of toilet seat covers

N350516
July 8, 2025
OT:RR:NC:N5:130
CATEGORY: Country of Origin Richard Writsman Continental Agency Inc 1768 W Second Street Pomona, CA 91766 RE: The country of origin of toilet seat covers Dear Mr. Writsman: In your letter dated June 23, 2025, you requested a country of origin ruling on behalf of your client, Jinan Hehe Paper Co., Ltd., for the purpose of duty calculation and Section 301 applicability. A detailed description of the manufacturing operations and samples were provided for our review. The paper products under consideration are toilet seat covers. Per your submission, bulk rolls of toilet seat cover tissue are manufactured in Indonesia. You describe the toilet seat covers as white/kraft paper: virgin; layer: 1;14 g/sm. These parent rolls of toilet seat cover tissue, which measure 360mm in width and have a maximum roll diameter 360mm, are then sent to China, where the tissue paper is embossed, folded, cut to size and sometimes octagonal shape, subjected to quality control, and packaged. When determining the country of origin for purposes of applying current trade remedies under Section 301, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). In China the tissue paper does not undergo a substantial transformation resulting in an item with a new name, character or use simply by embossing, folding, cutting, and packaging. The tissue paper is specifically dedicated for use as toilet seat covers and does not change into a new and different product by its working. As support, we reference existing Headquarters Ruling Letter (HQ) W967997, dated October 5, 2006, in which the processes of printing, cutting and folding tissue paper in a second country did not result in a substantial transformation. Likewise, in HQ 557462, dated September 13, 1994, the operations of cutting and folding were found to be merely finishing operations, which, again, did not constitute a substantial transformation.

The country of origin of the finished toilet seat covers is Indonesia. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 CFR 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Laurel Duvall at [email protected].
Sincerely,
(for) James Forkan Acting Director National Commodity Specialist Division